1101 K Street, NW, Suite 450, Washington, DC 20005

p: 202.446.1700 f: 202.216.9745 www.sia-online.org

October 24, 2011

BY EMAIL

The Honorable Lisa P. Jackson

Administrator

Environmental Protection Agency

Ariel Rios Building (1101A)

1200 Pennsylvania Ave NW

Washington, DC 20460

Petition For Reconsideration Of The Final Rule Pertaining To Protection Of Confidential Business 

Information Under The Mandatory Reporting Rules For Greenhouse Gases

Docket No. EPA-HQ-OAR-2010-0929

Dear Administrator Jackson:

The Semiconductor Industry Association (“SIA”)1petitions EPA for reconsideration of the final 

rule published on August 25, 2011 pertaining to the availability of confidential business information 

(CBI) protections under the greenhouse gas (GHG) emissions reporting regulation.2 We do so pursuant 

to Section 307(d)(7)(B) of the Clean Air Act3, which mandates that EPA “shall” grant reconsideration for 

“objections” “impracticable” to raise during the rulemaking and of “central relevance.”4

SIA seeks reconsideration on the three grounds explained below.

 

1

SIA is a trade association for the U.S. semiconductor industry, uniting companies responsible for more 

than 85 percent of U.S. semiconductor production. SIA is dedicated to maintaining our Nation’s world 

leadership in semiconductor technology, while at the same time supporting its members’ workplace safety

and environmental protection efforts. Collectively, the semiconductor industry employs a domestic 

workforce of approximately 200,000 people, and is our Nation’s largest exporting industry over the last 

five years. More information about the SIA can be found at www.sia-online.org.

2

See Change to the Reporting Date for Certain Data Elements Required Under the Mandatory Reporting of 

Greenhouse Gases Rule; Final Rule, 76 Fed. Reg. 53057 (Aug. 25, 2011) [hereinafter “Final CBI Rule” or 

“Final Rule”]. SIA filed comments on at least two Federal Register Notices that served as the predicate for 

the Final CBI Rule: (1) Proposed Confidentiality Determinations for Data Required Under the Mandatory 

Greenhouse Gas Reporting Rule and Proposed Amendment to Special Rules Governing Certain 

Information Obtained Under the Clean Air Act, 75 Fed. Reg. 38,959 (July 7, 2010) and (2) Call for 

Information: Information on Inputs to Emission Equations Under the Mandatory Reporting of Greenhouse 

Gases Rule” published by the U.S. Environmental Protection Agency (EPA or the Agency) at 75 Fed. Reg. 

81365 (Dec. 27, 2010).

3

42 U.S.C. § 7607(b)(1).

4

At the same time, SIA is filing Petition for Review of the Final CBI Rule with the United States Appellate 

Court of Appeals for the District of Columbia Circuit pursuant to Section 307(b)(1) of the Clean Air Act, 42 

U.S.C. § 7607(b)(1), and Rule 15(a) of the Federal Rules of Appellate Procedure.
 

1101 K Street, NW, Suite 450, Washington, DC 20005

p: 202.446.1700 f: 202.216.9745 www.sia-online.org

1. The Final CBI Rule Raises One Of The Same “Objections” As SIA’s Petition For Reconsideration Of 

the Final Subpart I

On January 31, 2011, SIA petitioned for judicial review and reconsideration of the Final Subpart 

I

5

of the GHG emissions reporting regulation.

6

 Among the “objections” raised in our Subpart I petition 

for reconsideration is the following that pertains to the vulnerability of intellectual property:

[T]he serious confidentiality concerns relating to the sharing of 

intellectual property inherent to [the current Subpart I’s] . . . recipebased reporting requirement.

7

 

The Final CBI Rule raises precisely this same intellectual property-vulnerability “objection”. 

In particular, the Final CBI Rule codifies EPA’s legal position that “inputs” to GHG “emissions 

equations” constitute “emissions data” that are not eligible for CBI protections and then applies this 

position to various elements of the current Subpart I.

8

 At the time of our Subpart I Petition for 

Reconsideration, this legal position had been proposed and not finalized,

9

but we covered in some 

detail in our petition the serious consequences for our intellectual property-vulnerability “objection” 

 

5 Mandatory Reporting of Greenhouse Gases: Additional Sources of Fluorinated GHGs; Final Rule, 75 Fed. 

Reg. 74,774 (Dec. 1, 2010), Subpart I to be codified at 40 C.F.R. § 98.90, et seq. (hereinafter “Final Subpart 

I” or “Final Rule”).

6

Semiconductor Industry Association v. EPA, Case No. 11-1024 (D.C. Cir. Filed Jan. 31, 2011); Semiconductor 

Industry Association Petition For Reconsideration And Request For Stay Pending Reconsideration Of 

Subpart I Of The Final Rule For Mandatory Reporting Of Greenhouse Gases Docket No. EPA-HQ-OAR-2009-

0927 (filed Jan. 31, 2011).

7

Petition for Reconsideration, at 3.

8

See Final CBI Rule, 76 Fed. Reg. at 53,062. In particular, the Final Rule makes determinations -- specific to 

the current Subpart I -- that certain reporting elements constitute “inputs” to “emissions equations” not 

entitled to CBI protections:

EPA agrees with the comments that the six data elements described above 

[pertaining to subparts Y and TT] are inputs to emission equations. In light 

of these comments, EPA reviewed the data elements lists to assure proper 

categorization and identified . . . additional data elements that are inputs to 

emission equations, but were not included in the December 27, 2010 

deferral proposal. These data elements are the following: 

• Subpart I: Fraction of each fluorinated GHG or N2O destroyed or removed 

in abatement systems connected to process tools where recipe, process 

sub-type, or process type j is used (40 CFR 98.96(o)).2 

• Subpart I: All inputs and results of calculations made accounting for the 

uptime of abatement systems used during the reporting year, in accordance 

with Equations I–14 and I–15 of this subpart (40 CFR 98.96(q)(2)).

9

See Proposed Confidentiality Determinations for Data Required Under the Mandatory Greenhouse Gas 

Reporting Rule and Proposed Amendment to Special Rules Governing Certain Information Obtained Under 

the Clean Air Act, 75 Fed. Reg. 38,959 (July 7, 2010).
 

1101 K Street, NW, Suite 450, Washington, DC 20005

p: 202.446.1700 f: 202.216.9745 www.sia-online.org

that would flow from this legal position, if finalized and applied to the current Subpart I. We excerpt 

pertinent portions of our Petition below:

10

Final Subpart I, although it does not mandate the submission of any 

full recipe, does require reporting of certain recipe-specific 

information. As explained below, this information could provide 

enough specific knowledge of proprietary device designs and 

manufacturing processes to allow for reverse engineering of 

individual recipes and otherwise would compromise the trade 

secrets within a company’s recipe portfolio.11

In particular, Section 98.96 of the Final Subpart I requires facilities to 

report the following information:

 Type of each gas used for each set of similar recipes;12 

 Recipe-specific utilization and byproduct rates (i.e., emission 

factors);13

 The film or substrate that was etched or cleaned and the 

feature type that was etched for each recipe in Part 

98.96(f)(1);14

 

10 Subpart I Petition for Reconsideration, at 18-22 (re-printed in the text of this petition below, with original 

footnotes).

11 In the semiconductor industry, reverse engineering involves starting with a known product and working

backwards to discover the process by which it was developed and manufactured. People v. Gopal, 171 

Cal. App. 3d 524, 533, (1985) (citing Kewanee Oil v. Bicron, supra, criminal conviction of misappropriation 

of trade secrets concerning semiconductors affirmed). It can be an arduous and expensive process that 

entails the purchase of a competitor’s chips, the cutting of chip cross-sections and the analysis of 

elemental materials through sophisticated atomic-level analytical techniques, stripping layers, 

photographing the circuitry of each layer through a scanning electron microscope, dissecting the chip to 

discover the layout design, constructing an electrical schematic of the circuitry, and then drawing 

inferences about the technical process used to make the device. Id.

The information implicated by the Final Subpart I reporting requirements (e.g., chemical identities, 

amounts, emitted, apportionment by process type, facility-wide consumption, annual gas consumption) is 

the type of information that could aid a competitor by short circuiting the time, effort, and money 

necessary to conduct reverse engineering or to conduct its own research and development. Moreover, 

these specific details would not necessarily be discernable, even from sophisticated reverse engineering.

And, the details at issue here are not for sale or otherwise available to the competition at a price. Keeping 

the details of valuable processes secret is critical to maintaining a competitive edge. This type of 

information clearly qualifies as trade secret. People v. Gopal, 171 Cal. App. 3d 524, 539 (1985) 

(information that would substantially reduce reverse engineering time is a trade secret).

12 § 98.96(c)(2).

13 § 98.96(f)(1).

14 § 98.96(f)(2).
 

1101 K Street, NW, Suite 450, Washington, DC 20005

p: 202.446.1700 f: 202.216.9745 www.sia-online.org

 Quantity of each gas used for each set of “similar” recipes, to 

be reported on an annualized basis;15 

 All apportioning factors used to apportion F-gas and N2O 

consumption;16 and 

 Identification of the quantifiable metric used in a facilityspecific engineering model to apportion gas consumption.17

The level of intellectual property inherent in the foregoing 

information is significant. Essentially, SIA understands these 

reporting requirements to require that a company reveal the 

quantity of gas being used (1) for each type of “film” being etched 

(e.g., oxide, nitride) and (2) for each “feature” within that film (e.g., 

gate, deep trench).18 As result, a company would be revealing 

information about its process and particular recipes used in that 

process which it, in many cases, has never shared publicly and which 

it regards as intellectual property. For example, a company would 

need, under these information requirements, to reveal that in its 300 

millimeter fabrication process, for a specific group of “similar” 

recipes it uses X kg of SF6 and Y kg of CHF3 to etch silicon nitride 

layers in gate stack in year 2010.

In addition, Final Subpart I would require each facility to maintain 

recipe-specific records in order to document compliance with the 

requirements of the Rule and make such records available to EPA. In 

particular, Section 98.97(b) of the Rule requires the following records 

be kept by any facility that estimates emissions using recipe-specific 

emission factors, i.e., “large” facilities: 

(1) “Complete documentation and final report for measurements for 

recipe specific [emission factors]”; and 

(2) “Documentation that recipe-specific [emission factors] developed 

for your facility are measured for recipes that are similar to those 

used at your facility, as defined in § 98.98. The documentation must 

include, at a minimum, recorded to the appropriate number of 

 

15 § 98.96(k).

16 § 98.96(l).

17 § 98.96(m)(i).

18 As defined in Section 3.1 of EPA’s Technical Support Document, a “film” is the material being etched, e.g., 

oxide, nitride, etc., while “feature” refers to the structure within which the film occurs, e.g., gate, deep 

trench, etc. See U.S. Environmental Protection Agency Office of Air and Radiation, Technical Support 

Document for Process Emissions from Electronics Manufacture (e.g., Micro-Electro-Mechanical Systems, 

Liquid Crystal Displays, Photovoltaics, and Semiconductors): Proposed Rule for Mandatory Reporting of 

Greenhouse Gases, Revised, November 2010 (“Technical Support Document”).
 

1101 K Street, NW, Suite 450, Washington, DC 20005

p: 202.446.1700 f: 202.216.9745 www.sia-online.org

significant figures, reactor pressure, flow rates, chemical 

composition, applied RF power, direct current (DC) bias, 

temperature, flow stabilization time, and duration.”19

Of particular concern to SIA and its members is that these records 

could become subject to inquiries as to their content and sufficiency 

not only by EPA in an enforcement context, but also by local 

residents and other private citizens in future permitting and related 

contexts (e.g., a Freedom of Information Act Request or through 

discovery in a citizen suit filed under the Clean Air Act).20 Etch 

recipes are considered trade secrets and, as such, are tightly 

controlled. Most semiconductor companies – even very prolific 

patentees – opt to protect their recipes as trade secrets, rather than 

through patents, which require disclosure of the recipe. If these 

records are made public, they could loose their status as trade 

secrets, allowing competitors to reverse engineer recipes, thereby 

compromising the value of information worth up to several billion 

dollars to each company. 

The loss of trade secret protection for semiconductor etch recipe 

information through its public disclosure via the Final Rule could 

amount to a regulatory taking of intellectual property.21 It does not 

appear that EPA (or the Office of Management and Budget) has 

undertaken any analysis of this potential erosion of private 

intellectual property value. In addition to this potential takings issue, 

disclosure of recipe information may also present national security 

concerns at those semiconductor facilities that are designated 

Trusted Foundries by the U.S. National Security Agency.22

Moreover, EPA has not yet finalized its position on what information 

submitted under the Reporting Rule constitutes “emissions data” 

that are not subject to confidential treatment under the CAA. 

Section 114(c) of the Clean Air Act provides that “records, reports or 

information” submitted to EPA in connection with a rulemaking or 

“standards” development or as part of an ongoing compliance 

requirement or through an investigation or enforcement proceeding 

may be maintained as confidential so long as they do not constitute 

 

19 § 98.97(b).

20 As of July 1, 2011, many semiconductor facilities will be subject to the CAA’s Prevention of Significant 

Deterioration permitting under the GHG “Tailoring Rule.” See Prevention of Significant Deterioration and 

Title V Greenhouse Gas Tailoring Rule; Final Rule, 75 Fed. Reg. 31,514 (June 3, 2010).

21 Trade secrets have long been recognized as property protected by the United States Constitution and 

other laws. Ruckelshaus v. Monsanto Co., 467 U.S. 986 (1984) (environmental data can be trade secret; 

unauthorized disclosure is a taking).

22 See http://www.nsa.gov/business/programs/tapo.shtml.
 

1101 K Street, NW, Suite 450, Washington, DC 20005

p: 202.446.1700 f: 202.216.9745 www.sia-online.org

“emissions data.”23 Under EPA’s regulations, the determination of 

which information is “emissions data” has been made on a case-bycase basis based on information submitted by individual emission 

sources.

24

 

In July 2010, EPA published a proposal (hereinafter “Proposed CBI 

Rule”) that, if finalized, will constitute EPA’s prospective 

determination of which information required to be submitted under 

Subpart I will qualify as “emissions data” and, therefore, will not be 

eligible for confidential treatment under the Rule.25 The Proposed 

CBI Rule identifies which information EPA will consider “emissions 

data” by reference to specific sections in Subpart I. At the time of its 

publication in July 2010, the Proposed CBI Rule referred to the 

information requirements of Subpart I as they existed then; this was 

the Re-Proposed Subpart I, which, as described in Section II(B)(1)(a) 

above, required submission of information, including emission 

factors under § 98.96(d), only for certain process categories, and not 

on a recipe-specific basis. Therefore, the determination of which 

data submitted under Subpart I constitute “emissions data” was 

made by EPA without any evaluation of the Final Subpart I’s recipespecific reporting regime. 

If EPA were to persist in its position articulated in the Proposed CBI 

Rule, much of the information underlying the Final Subpart I’s 

emissions calculations,26 including the recipe-specific emissions 

factors, would constitute “emissions data,” thereby making recipespecific information vulnerable to public disclosure even more 

broadly outside the enforcement and permitting contexts described 

above. Although SIA commented on the Proposed CBI Rule,27 it was 

obviously impracticable for SIA to comment on the Proposed CBI 

Rule as it would ultimately apply -- i.e., to the submission of recipespecific emission factors. 

 

23 42 U.S.C. § 7471(c).

24 See 40 C.F.R. § 2.301 et seq. 

25 See Proposed Confidentiality Determinations for Data Required Under the Mandatory Greenhouse Gas 

Reporting Rule and Proposed Amendment to Special Rules Governing Certain Information Obtained Under 

the Clean Air Act, 75 Fed. Reg. 38,959 (July 7, 2010).

26 See EPA, “Data category assignments for reporting elements to be reported under 40 CFR part 98 and its 

amendments,” pp. 18-21, available at

http://www.epa.gov/climatechange/emissions/downloads10/CBI_Data-Category.pdf).

27 See Comments of the Semiconductor Industry Association on EPA’s Proposed Confidentiality

Determinations for Data Required Under the Mandatory Greenhouse Gas Reporting Rule and Proposed 

Amendment to Special Rules Governing Certain Information Obtained Under the Clean Air Act, EPA Docket 

No. EPA-HQ-OAR-2009-0924-0043.1 (Sept. 7, 2010).
 

1101 K Street, NW, Suite 450, Washington, DC 20005

p: 202.446.1700 f: 202.216.9745 www.sia-online.org

The mere fact that the Final Subpart I would probe so deeply into the 

semiconductor fabrication process as to create such vulnerabilities to 

intellectual property underscores why an individual recipe-based 

approach is not sound for the long term, even if EPA were to address 

the definitional and other issues to render the Final Subpart I 

technically feasible. In addition, EPA utterly failed to recognize and 

address these intellectual property threats when promulgating the 

Final Subpart I, and therefore, EPA must grant reconsideration on 

this issue to rectify these serious gaps in its legal and policy analysis.

As the foregoing excerpt from our Subpart I Petition for Reconsideration indicates, the Final CBI 

Rule raises the same intellectual property-vulnerability “objection” as our petition. Thus, to preserve 

our legal rights as to this objection, SIA submits today’s petition for reconsideration of the Final CBI 

Rule.

2. The Final CBI Rule Is Material To The Current Effort -- Pursuant To SIA’s Subpart I Petitions For 

Reconsideration And For Judicial Review -- To Develop GHG Reporting Alternatives

EPA granted SIA’s Subpart I Petition for Reconsideration in part to defer the recipe-based 

reporting requirement for 3 years.28 SIA and EPA are now engaged in data gathering and discussions 

aimed at exploring three potential alternatives to the current Subpart I. These discussions are occurring 

pursuant to the grant in part of SIA’s Petition for Reconsideration as well as its Petition for Judicial 

Review, which is currently being held in abeyance.

As noted above, the Final CBI Rule codifies the legal position that “inputs” to GHG “emissions 

equations” constitute “emissions data” that are not eligible for CBI protections. In doing so, however, 

the Final Rule defers the effective date of this legal position so that EPA can analyze its CBI implications 

for each subpart, and, if warranted and feasible for any subpart, engage in further rulemaking to revise 

that subpart in a manner that would avoid making CBI public.29 

Having a separate process to address CBI that is disconnected from the current effort to 

develop alternatives to the current Subpart I will -- by definition -- deprive SIA and its members of their 

due process rights. The viability of any alternative to the current Subpart I now being discussed with 

EPA depends upon ensuring adequate resolution of SIA’s intellectual property-vulnerability “objection” 

raised in its Subpart I Petition for Reconsideration and now raised, as discussed in Section 1. above, in 

this petition for reconsideration. The notion that the alternatives to the current Subpart I would be 

adopted, and only then evaluated separately for CBI protection -- with the possibility that EPA would 

conclude, based in its legal position, that intellectual property underlying an alternative are not eligible 

for CBI protections and must be made public – would have the result of nullifying SIA’s intellectual 

property-vulnerability “objection” for both its Subpart I Petition for Reconsideration and this current 

petition. 

 

28 Mandatory Reporting of Greenhouse Gases: Changes to Provisions for Electronics Manufacturing to 

Provide Flexibility, 76 Fed. Reg. 59,542 (Sept. 27, 2011).

29 Final CBI Rule, 76 Fed. Reg. 53061.
 

1101 K Street, NW, Suite 450, Washington, DC 20005

p: 202.446.1700 f: 202.216.9745 www.sia-online.org

As further evidence of such nullification, EPA has indicated during discussions to date that the 

Agency may not replace the current recipe-based approach with one or more alternatives, but instead, 

retain it as one reporting “option”. Although SIA believes that the recipe-based approach is not legally 

permissible for various reasons addressed in our Subpart I Petition for Reconsideration, should EPA 

decide to retain it, then the 2-part process envisioned by the Final CBI Rule likewise would not allow for 

resolution of our intellectual property-vulnerability “objection” through our Subpart I Petition for 

Reconsideration and this current petition.

As the foregoing indicates, SIA’s “objection” to the two-part process established by the Final CBI 

rule more than satisfies the Section 307(d)(7)(B) reconsideration standard: Indeed, SIA’s “objection” to 

the 2-part process certainly was “impracticable” to raise during the rulemaking for the Final CBI Rule. 

Moreover, it is clearly of “central relevance given that such a disconnected, 2-part process would 

undermine proper and full resolution of its intellectual property-vulnerability “objection” raised in this 

as well as SIA’s Subpart I Petition for Reconsideration.

3. The Procedural Confusion Surrounding The Final CBI Rule Likewise Provides A clear Basis For 

Reconsideration

As described in its Preamble,30 the Final CBI Rule grows out of a web of regulatory actions, 

including:

 A July 7, 2010 proposal that would (a) codify the legal position that “inputs” to “emissions 

equations” constitute “emissions data” for which CBI protections are not available and (b) 

categorize the various data elements of each Part 98 GHG reporting subpart based on this legal 

position.

 A July 27, 2010 supplemental proposal to the July 7, 2010 proposal to address revised and new Part 

98 data elements.

 An August 11, 2010 proposal that would revise Part 98 to change the description of some data 

elements and to add others.

 A December 27, 2010 interim final rule that deferred reporting of “inputs” to “emissions equations” 

until August 31, 2011.

 A December 27, 2010 “call for information” relevant to EPA’s “evaluation of data elements being 

deferred”.

 A March 18, 2011 interim final rule that extended the reporting deadline for all information until 

September 30, 2011.

This web of actions has created a confusing and uncertain situation -- especially for SIA and its member 

companies -- that provides an independent basis for reconsideration pursuant to Section 307(d)(7)(B)’s 

mandate that EPA “shall” grant reconsideration for “objections” “impracticable” to raise during the 

rulemaking and of “central relevance.

 

30 Final CBI Rule, 76 Fed. Reg. 53060-61.
 

1101 K Street, NW, Suite 450, Washington, DC 20005

p: 202.446.1700 f: 202.216.9745 www.sia-online.org

In particular, the Final CBI Rule appears to finalize the notice and comment rulemaking process 

for at least two of the foregoing actions: (1) The July 7, 2010 proposal and (2) the December 27, 2010 

“call for information”. SIA lacked adequate opportunity to comment on each of these actions.

As to the first action, publication of the Final Subpart I -- on December 1, 2010 -- occurred many 

months after the July 7, 2010 action in which EPA proposed a legal position that, as explained in Section 

2 above, goes to the heart of our intellectual property-vulnerability “objection”. It is clear, therefore, 

that SIA lacked an adequate opportunity to comment on the July 7, 2010 action with respect to the full 

and specific import of this legal position, given that Subpart I had, at that point, been proposed, then 

withdrawn and re-proposed, but had not been finalized. 

As to the second action, publication of the Final Subpart I -- on December 1, 2010 -- occurred 

just a few weeks before the December 27, 2010 action. By December 27th, SIA already had met several 

times with EPA informally to request withdrawal of the Final Subpart I, based in part on its intellectual 

property-vulnerability “objection”, and then made this request in writing only a two days after 

December 27th.

31

 On or about January 19, 2011, SIA learned that EPA would not withdraw Subpart I and 

that a petition for reconsideration would be needed to address SIA’s concerns, and on that same date, 

EPA extended the scheduled close of the comment period for the December 27th action to February 3, 

2011. A few weeks later, on January 31, 2011, SIA filed its Subpart I Petition for Reconsideration in 

which we formally lodged our intellectual property-vulnerability “objection”; comments on the 

December 27, 2011 action were due a few days later, and in those comments, SIA noted this same 

“objection.

32

 

Under the circumstances, SIA seeks reconsideration of the Final CBI Rule to address its 

inadequate opportunity to comment. We also do so as a precautionary measure due to the confusion 

and uncertain situation created by the web of actions that preceded the Final CBI Rule.

* * *

As the foregoing indicates, SIA has more than ample grounds to obtain reconsideration of the 

Final Subpart I under Clean Air Act Section 307(d)(7)(B)’s 2-part “impracticable” and “central relevance” 

test. SIA requests that EPA grant our petition for reconsideration of the Final CBI Rule and consolidate 

our “objections” with the current effort to resolve SIA’s Subpart I petitions for reconsideration and 

judicial review.

Sincerely,

David Isaacs

Vice President, Government Policy

 

31 Letter to Administrator Jackson from SIA re: “Subpart I of Recently Finalized GHG Reporting Rule for 

Additional Sources of Fluorinated Gases: Request for Withdrawal” (Dec. 29, 2010). 

32 Comments on the December 27 action were originally due on February 3, 2011, and SIA’s Subpart I 

Petition for Reconsideration was due (and was filed) on January 31, 2011. On January 19, 2011, the 

February 3, 2011 deadline was extended to March 7, 2011. 
 

1101 K Street, NW, Suite 450, Washington, DC 20005

p: 202.446.1700 f: 202.216.9745 www.sia-online.org

Cc: Carole Cook

Climate Change Division

Office of Atmospheric Programs (MC–6207J)

Environmental Protection Agency

1200 Pennsylvania Ave., NW.

Washington, DC 20460

Associate General Counsel for the Air and Radiation Law Office

Office of General Counsel (Mail Code 2344A)

Environmental Protection Agency

1200 Pennsylvania Ave., NW.

Washington, DC 20004
 

1101 K Street, NW, Suite 450, Washington, DC 20005

p: 202.446.1700 f: 202.216.9745 www.sia-online.org